Paint Stripping & Misc.

On January 9, 2008 the US Environmental Protection Agency (EPA) promulgated 40 CFR Part 63, Subpart HHHHHH -—National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources (hereafter referred to as Subpart 6H). This rule combines three source categories: Paint Stripping, Miscellaneous Surface Coating, and Motor Vehicle and Mobile Equipment Surface Coating. This last category includes facilities, such as body shops, where coatings are sprayed on automobiles, trucks, or motorcycles. However, this category also covers the spray coating of mobile equipment, meaning "any device that may be drawn and/or driven on a roadway," such as trailers, agricultural equipment, and recreational vehicles.

Subpart 6H is applicable to any person who owns or operates such a motor vehicle or mobile equipment surface coating facility and is an area source of hazardous air pollutant (HAP) emissions. An area source of HAP emissions is any stationary source (facility) that does not have the potential to emit any single HAP at a rate of 10 tons per year or more and any combination of HAPs at a rate of 25 tons per year or more.

Facilities subject to Subpart 6H are required to implement various equipment, training, and management practices designed to minimize coating usage and overspray in an effort to reduce the emission of five target HAPs: compounds of cadmium, chromium, lead, manganese, and nickel. The equipment practices include confining spray operations to within a properly filtered spray booth or preparation station and using high volume, low pressure (HVLP) spray guns, or equivalent.

Further, sources subject to Subpart 6H that began operation on or before September 17, 2007 are required to be in compliance by January 10, 2011, sources (including reconstructed sources) that began operation after September 17, 2007 are required to be in compliance already, and future sources (including reconstructed sources) are required to be in compliance at startup.

If you have any questions regarding this rule, please call (828) 250-6777.